Assessable value must track actual depot-wise sale prices; withheld sales data can justify extended limitation in duty reassessment.

Assessable value under Section 4(1)(a) must reflect the normal price at the actual time and place of removal, so a single notional depot price cannot be treated as the uniform value for all clearances where goods are sold through different depots at different prices. The valuation exercise must consider depot-wise sales and permissible abatements, including freight and insurance, on complete commercial data. Where relevant pricing and sales details are withheld, suppression of material facts may justify reopening the demand under the extended limitation period under Section 11A.

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Issues: (i) whether the price declared on the basis of the Calcutta depot price was the correct assessable value under Section 4(1)(a); (ii) whether the demand was barred by limitation under Section 11A.

Issue (i): whether the price declared on the basis of the Calcutta depot price was the correct assessable value under Section 4(1)(a).

Analysis: The relevant price under Section 4(1)(a) is the normal price at which goods are ordinarily sold at the time and place of removal. Where the same goods were actually sold from different depots at different prices, a notional Calcutta price could not automatically be treated as the sole assessable value for all clearances. The record showed that the assessees had not furnished complete data regarding sales from different depots, freight, insurance, and other elements needed to test whether the declared price reflected the actual commercial pattern. The proper course was therefore to examine the actual depot-wise prices and, if necessary, apply the valuation rules after permissible abatements.

Conclusion: The Calcutta depot price could not be mechanically accepted as the uniform assessable value for all clearances; the matter required fresh examination on the basis of actual depot-wise sales and valuation principles.

Issue (ii): whether the demand was barred by limitation under Section 11A.

Analysis: The Tribunal accepted the assessees' assertion as to the date of receipt of the show cause notice, since the Revenue could not show an earlier service. On the facts found, the non-disclosure of correct pricing information and the withholding of relevant sales details amounted to suppression of material facts, so the extended period was available if the reassessed duty so warranted.

Conclusion: The demand was not barred by limitation on the Tribunal's finding that the extended period could apply.

Final Conclusion: The appeal succeeded only to the extent that the valuation and related duty liability were sent back for fresh determination; the limitation objection failed.

Ratio Decidendi: Under Section 4(1)(a), the assessable value must be based on the actual normal price at the relevant depot or place of removal, and where material sales details are withheld, the matter may be reopened within the extended limitation period under Section 11A.

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